2013 IATA Updates

Applicability

• Incident and Accident Reporting: A new paragraph has been added recommending that entities other than operators report dangerous goods incidents or accidents and undeclared or misdeclared dangerous goods identified while in their possession.

Limitations

• 2.3-Dangerous Goods Carried by Passengers or Crew. There have been extensive changes and additions to the provisions for dangerous goods permitted in passenger and crew member baggage. These include:
  • revision to the provisions for battery-powered mobility aids to make provision for lightweight mobility aids that are designed to be collapsible and have the battery removed;
  • clarification that small cartridges containing a Division 2.2 gas may be carried in checked or carry-on baggage;
  • revision to allow all permitted types of fuel cell cartridges in checked baggage;
  • allowance for non-spillable batteries in equipment in baggage, subject to limitations on the size of the battery.
• 2.6.10-De Minimis Quantities. New provisions have been added to address transport of very small quantities of certain dangerous goods. This is a significant change which aligns US DOT and IATA regulations for shipping certain dangerous goods in receptacles of up to 1 mL for liquids and gases and 1 g for solids. As long as the package is assembled properly following this section, the Excepted Quantity label is not needed.

Classification

• 3.6.2.2.3-Newprovisions have been added to address the transport of uncleaned medical devices/ equipment.
• 3.9.2.6-Provisions have been added to identify the requirements for lithium batteries, including requirements for manufacturers to have a quality management system.

Special Provisions

• A number of special provisions that include provisions for certain substances and articles to be "not subject to these Regulations" have been revised to limit the application to when the substances or articles are carried as cargo, see A32, A41, A47, A67, A69, A70, A98 and A129.
• A189-clarifies the requirements for formaldehyde solutions with less than 25% formaldehyde.
  • with 10% or more, but less than 25% formaldehyde must be classified as UN 3334 Aviation regulated liquid, n.o.s. , and
  • with less than 10% formaldehyde are not subject to the regulations.
• A191-provides for an exception to the requirement for manufactured articles containing mercury to have to show the Division 6.1 subsidiary risk on the Shipper's Declaration and for the packages to have to bear a Toxic hazard label.

Packing Instructions

• Almost all of the packing instructions have been revised to include closed head drums (1A1, 1B1, 1H1 and 1 N1) and/or other metal boxes (4N) as outer packagings.
• The absorbent material requirements in Packing Instructions 350, 351, 360, 361, 373, Y373, 493, 494, 553, 651, 652, 657, 658, 680, 850 and 854 have been revised to require sufficient absorbent material to absorb the entire contents of the inner packagings.
• 965 and 968-the packing instructions applicable to lithium ion and lithium metal batteries have been revised to limit the quantity of lithium batteries that may be placed in a package under the provisions of Section II. A new Section IB has been added to these packing instructions that permit small lithium batteries meeting the general requirements of Section II to continue to be shipped in non-UN specification packagings up to a total package weight of 10 kg. Shipments prepared according to Section IB are subject to all of the applicable requirements of these Regulations, including that for dangerous goods training. Section IB shipments do not require the full Shipper's Declaration but do require an abbreviated document or information on the air waybill as indicated in the packing instructions. Section I of these packing instructions has been revised to become Section IA. The package limits specified in Section IA have been revised to become net quantity per package rather than gross weight.
• 966 and 969-the packing instructions applicable to lithium ion and lithium metal batteries packed with equipment have been revised to clearly apply a limit on the net quantity (weight) of lithium batteries that may be placed in a package under the provisions of both Section I and Section II. The limit for Section I is 5 kg net on a passenger aircraft and 35 kg net on a cargo aircraft. For Section IIthe limit is 5 kg net per package for both passenger and cargo aircraft.
• 967 and 970-the packing instructions applicable to lithium ion and lithium metal batteries contained in equipment have been revised to clearly apply a limit on the net quantity (weight) of lithium batteries that may be placed in a package under the provisions of both Section I and Section II. The limit for Section I is 5 kg net on a passenger aircraft and 35 kg net on a cargo aircraft. For Section IIthe limit is 5 kg net per package for both passenger and cargo aircraft.

Training Requirements
 
Who Must be Trained: Have you asked yourself this question? Very often, companies will only train and certify Shipping and Receiving personnel and forget about other employees who have a role in their company's dangerous goods shipping process. 

A common situation that puts companies out of compliance and at risk occurs when employees (e.g., lab personnel) without the proper training and certification package or even partially package a dangerous good.  The DOT has made it clear that employees who even "partially" assemble a dangerous goods package must be properly trained and certified.  This means that even employees who place sealed primary containers (e.g., a bottle of a regulated dangerous good) in an outer shipping box, which they provide to Shipping and Receiving personnel to inspect, close, and mark and label, are themselves required to be trained and certified.  

As a reminder, per 49 CFR and HM-223**, all employees who affect hazardous materials/dangerous goods* transportation safety must be properly trained and certified.  This includes employees who:

• Determine a material's hazard class(es);
• Select the packaging;
• Fill and close a packaging;
• Mark and label a package;
• Prepare or review shipping papers and emergency response information;
• As an importer of hazardous materials/dangerous goods*, provide the shipper with shipping requirements that will apply to the transportation of the material within the United States;
• Certify that a hazardous material/dangerous good* is in proper condition for transportation;
• Load, block, and brace a hazardous material/dangerous good* package in a freight container or transport vehicle;
• Segregate a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
• Select, provide, or affix placards for a freight container or transport vehicle to indicate that it contains a hazardous material/dangerous good*.

• General familiarization training
• Function-specific training
• Safety training
• Security awareness training

Our Training Solution
 
Focused on What You Ship:
Save money and time and improve compliance by making the training applicable to your employees.  Employees do not need to attend a 2 or 3 day offsite training course which may spend much of the time on irrelevant topics and completely miss the ones that your employees really need to know well.  The program I offer can often be completed in a single 1-day session (or several 3-4 hour sessions) at your facility.  In addition, the testing and certification can also be customized to the specific job functions and even include applicable practical exercises using the actual packaging, software, etc that your employees use.     

Added Value: Find and Fix Problems

Ultimately companies should be focused on compliance.  And a valuable outcome of onsite training is discovering and fixing problems in shipping programs during the training.  

Added Value: Your Very Own Shipping Guidelines:
Included in the training can be shipping guidelines/checklists customized to the types of materials you commonly ship.  These can also include procedures and forms for carriers that you use (e.g., FedEx, World Courier, UPS, DHL).  

 
More Added Value: Packaging Solution Consultation:
Working with a number of packaging vendors over the years, I can assist your organization in developing customized packaging solutions.

• Chemical safety audits
• Safety training, both in person and hosted web-based
• Onsite and special project support
• HMBP and chemical inventory services (including uploads to CERS)
• Hazardous waste auditing, minimization and reporting
• Bloodborne Pathogens (annual requirement)
• Hazard Communication 
• Chemical Hygiene Plan 
• Laser Safety
• Biological Safety 
• Radiation Safety
• Shop Safety
• Many others, please contact me